UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION: Randy Steven Dixon FOR AN EXEMPTION SEEKING 

RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) 

& (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 UAS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Name and Address of the Petitioner

Randy Steven Dixon 

731 Oak Knoll Circle, Auburn, AL 36830 

334.444.6238 

steven@stevendixonmedia.com 

Submitted on June 15, 2015

Randy Steven Dixon, owner and operator of Tiger Motion Productions, LLC dba Steven Dixon Media 

seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft 

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit Randy Steven Dixon to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of real estate, and landscape over

certain areas of the United States. 

Randy Steven Dixon provides his clients with photography and videography of properties for the 

purpose of advertising. Randy Steven Dixon has been in business since June of 2009 as a video producer 

and has 2 years recreational/hobby experience in all aspects of aerial video and photography. Many of 

Randy Steven Dixon’s clients have requested aerial photo and aerial video services in the past, however 

due to FAA Rules and Regulations, he has yet to provide the services. Randy Steven Dixon hopes to offer 

aerial operations and provide the best and highest quality video and pictures for commercial, public, and 

residential needs. Randy Steven Dixon’s current target market includes, Residential Construction, Realestate, and filmmaking.

The UAS that Randy Steven Dixon owns is the DJI Phantom 3 UAS. Randy Steven Dixon seeks an 

exemption to operate his DJI Phantom 3 for compensation or hire within the national air space. The DJI 

Phantom 3 is a vertical takeoff and landing unmanned aircraft with a ground control station utilizing an 

electronic tablet or smart phone. The DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Phantom 3 UA is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. 
Randy Steven Dixon, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) 

and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI 

Phantom 3 UA in the National Airspace System, and for an exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with 

the unmanned aircraft and its operation, Randy Steven Dixon operation of DJI Phantom 3 UAS meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Randy Steven Dixon requests relief from 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. Randy Steven 

Dixon submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Randy Steven Dixon will use experienced personnel or technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). 

Furthermore, Randy Steven Dixon will document and maintain all maintenance records for the DJI 

Phantom 3 UAS. 

Randy Steven Dixon seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Phantom 3 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Randy Steven Dixon submits that he will ensure that the DJI Phantom 3 UAS are in 

an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that 

the aircraft is in a condition for safe flight. Randy Steven Dixon also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 UA will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3UA will be 

provided to the pilot in command via GPS equipment and radio communications telemetry data link, 

which downlinks from the UA to the ground control station for active monitoring of the flight path. The

altitude information, combined with Randy Steven Dixon’s operation of the DJI Phantom 3 UAS within 

visual line of sight, at or below 500 feet above ground level, will ensure a level of safety equivalent to 

Section 91.121. Additionally, Randy Steven Dixon seeks an exemption from the requirements of Section 

91.151(b), entitled fuel requirements for flight in visual flight rules conditions. 

Randy Steven Dixon submits that safety will not be affected by operation of the DJI Phantom 3 UAS

during daylight hours under visual flight rules, with enough battery power to fly for a total duration of 

approximately 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, 

The Specific Sections Of 14 C.F.R. From which Randy Steven Dixon seeks exemption. 

1. Randy Steven Dixon Seeks Exemption From The Requirements Of Section 61.113(a) and (b). Section 

61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as PIC of an aircraft. 
(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Randy Steven Dixon Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Randy Steven Dixon seeks exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection 

(a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude 

or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure. 

4. Randy Steven Dixon Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 20 minutes. 

5. Randy Steven Dixon seeks exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter[.] 

6. Randy Steven Dixon Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, 

entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection 

(a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] 
7. Randy Steven Dixon Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. 

8. Randy Steven Dixon Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief Randy Steven Dixon Seeks And The Reason Randy Steven Dixon Seeks The Relief. 
1. Extent Of Relief Randy Steven Dixon, Seeks And The Reason Randy Steven Dixon Seeks Relief From 

Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, 

is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as 

well as a current and valid airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is 

requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for 

compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. As set forth more fully below, Randy Steven Dixon submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the Phantom 3 

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

is able to safely operate either the DJI Phantom 3 UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, Randy Steven Dixon submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Randy Steven Dixon’s business; and (2) will 

not carry passengers or property for compensation or hire. 

2. Extent Of Relief Randy Steven Dixon Seeks And The Reason Randy Steven Dixon Seeks Relief From 

Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow Randy Steven Dixon to determine that the DJI Phantom 3 UAS are in airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Randy 

Steven Dixon Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction 

Manual). 

Randy Steven Dixon seeks the requested relief because the DJI Phantom 3 UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Randy Steven Dixon 

will ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) prior to 

every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below. 

3. Extent Of Relief Randy Steven Dixon Seeks And The Reason Randy Steven Dixon Seeks Relief From 

Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station. Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control in feet above ground level, Randy Steven Dixon seeks the 

requested relief because the DJI Phantom 3 UA altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight. Considering the limited 

altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to 
comply with the applicable conditions and limitations stated below. As more fully set forth herein, an 

equivalent level of safety will be maintained since the DJI Phantom 3 UA are equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting 

will be established prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS. 

4. Extent Of Relief Randy Steven Dixon Seeks And The Reason Randy Steven Dixon Seeks Relief From 

Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, 

is requested to the extent required to allow flights of the battery powered DJI Phantom 3 UA during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. Randy Steven Dixon seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UA

will severely constrain the practicality of any aerial video or still photo flight operations that Randy 

Steven Dixon proposes to conduct pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the DJI Phantom 3 UAS, and DJI Phantom 3 operating documents, and Randy 

Steven Dixon’s proposed operating limitations, ensure that Randy Steven Dixon will safely operate the 

battery powered DJI Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 14.5 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. 

5. Extent Of Relief Randy Steven Dixon Seeks And The Reason Randy Steven Dixon Seeks Relief From 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft 

with an airworthiness certificate, Randy Steven Dixon requests relief from these Sections because the 

DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Randy Steven Dixon will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the Randy Steven Dixon Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Randy Steven Dixon 

will document and maintain all maintenance records for the DJI Phantom 3 UAS. 

D. The Reasons Why Granting Randy Steven Dixon Request Would Be In The Public Interest; That Is, How 

It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Randy Steven Dixon to safely, 

efficiently, and economically perform aerial video and photography for real estate, film sets, and 

landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3 UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of Randy Steven Dixon’s proposed operation of the DJI Phantom 3 UAS will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 
The DJI Phantom 3 UA is battery powered and serve as a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. Furthermore, by reducing the 

number of manned aircraft operating in the NAS, congestion around airports caused by arriving and 

departing aircraft will be reduced. The DJI Phantom 3 UA does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result 

in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of theDJI Phantom 3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

motors, the DJI Phantom 3 UASs produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The DJI Phantom 3 UAs, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an 

internal combustion engine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UA

(weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at its maximum 

gross weight with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches 

respectively, and with no fuel on board), has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 

34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations with the DJI Phantom 3 UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS 

will allow United States based companies, like Randy Steven Dixon, to remain competitive and 

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI 

Phantom 3 UAS, companies such as Randy Steven Dixon, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately contribute to 
growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial 

use of the DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves 

local, state, and federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Randy 

Steven Dixon’s proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. 

Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., 

the Randy Steven Dixon Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Instruction Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption 

Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Randy Steven 

Dixon Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, Randy Steven Dixon’s operation of the DJI Phantom 3 UASs meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart 

H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days 

after the date of enactment of this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this 

Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the 

Secretary shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight do not 

create a hazard to users of the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system. 
In seeking this exemption, Randy Steven Dixon submits that the DJI Phantom 3 UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 

UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe Characteristics. The DJI Phantom 3 

UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 UASs. The technical specifications of the DJI Phantom 3 

UAS are set forth by the and DJI Phantom 3 User Manuals, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within 

A Defined Operational Area. The DJI Phantom 3 UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of the DJI 

Phantom 3 UAS is provided at pages 12-16 and 45-50 of the DJI Phantom 3 User Manual, attached

hereto as Appendix A. The DJI Phantom 3 UAS is Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI 

Phantom 3 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 UA does not reacquire control link data from the GCS, the UAs will assume that the Control 

Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to 

the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 

3 at pages 13 through 15 of the DJI Phantom 3 User Manuals, attached hereto as Appendix A.

The DJI Phantom 3 GCS and Its Operation. A complete description of the operation and specifications of 

the DJI Phantom 3 GCS and flight control software is provided at pages 40 through 47 of the DJI 

Phantom 3 User Manual. DJI Phantom 3 User Manuals are attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. Randy Steven Dixon will be the only person to act as a pilot in 

command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist in flights. 

c. Flights Of the DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In 

seeking this exemption, Randy Steven Dixon proposes to commercially operate the DJI Phantom 3 UAS

for the special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI 

Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within 

visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision 
unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 

operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/ obstructions and is not permitted to operate the camera or 

other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations contained in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The 

PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the UAS 

to service. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 
17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS 

will be operated under the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must 

be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the exemption. However, training operations may only 

be conducted during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s 

COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also 

require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities 

at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. Randy Steven Dixon submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 

3 UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. Considering Randy Steven Dixon’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI Phantom 3 UAS, Randy Steven Dixon submits that 

the additional manned airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for Randy Steven Dixon’s specific proposed flight operations. The FAA 

has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 

11161). Randy Steven Dixon will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner 
consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a 

UAS pilot operating the same make and model of UAS to be used for operations under the exemption). 

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained 

in compliance with applicable regulations will ensure an equivalent level of safety during KYLE P 

NORTON’s proposed operations. The Administrator has held that prior documented flight experience 

that was obtained in compliance with applicable regulations would ensure safe operations, stating as 

follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 

11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating 

the same make and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make 

and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included 

in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that 

at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and 

build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance with applicable 

regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also 

be conducted under the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Randy 

Steven Dixon will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Randy Steven Dixon will ensure that the DJI Phantom 3 UAS is in an airworthy condition 

based upon the UAS’s compliance with its operating documents and as stated in the conditions and 

limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety. 
The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the DJI Phantom 3 UAs will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of 

the flight path and altitude. This altitude information, combined with Randy Steven Dixon’s operation of 

the DJI Phantom 3 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by 

the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect 

Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the limitations on 

the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

Randy Steven Dixon will ensure that it will safely operate the battery powered DJI Phantom 3 UAs during 

daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes 

to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 

4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will ensure 

an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be 

ensured as the DJI Phantom 3 UASs provide audible and visual warnings to the PIC at the GCS when the 

UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining 

battery power, and again at approximately 10% remaining battery power. At the critically low battery 

level, the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions 

granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption 

Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 

specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Randy 

Steven Dixon submits that the equivalent level of safety with regard to the regulatory maintenance and 

alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because Randy Steven Dixon will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Randy Steven Dixon Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Randy Steven Dixon 

will document and maintain all maintenance records for the DJI Phantom 3 UAS. Since the DJI Phantom 
3 UASs will be inspected as prescribed by the operating documents, Randy Steven Dixon will maintain 

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of 

the DJI Phantom 3 User Manuals are attached hereto as Appendix A; a copy of the DJI Phantom 3 UAS 

Maintenance LOG is attached hereto as Appendix B. Likewise, the exemption sought will not adversely 

affect safety because Randy Steven Dixon will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. Furthermore, the exemption sought would maintain an 

equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the DJI Phantom 3 UASs will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions 

granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) establish that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. In consideration of Randy Steven Dixon’s proposed operating 

limitations, the operating documents, and the technical aspects of the DJI Phantom 3 UASs, Randy 

Steven Dixon submits that safety will not be adversely affected by granting exemption from 14 C.F.R. 

Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special 

Conditions, Randy Steven Dixon requests that the FAA prescribe special conditions for the intended 

operation of the DJI Phantom 3 UASs, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited 

purpose of conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, 

the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 

DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of 

this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, 

or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he 

prescribes special conditions and amendments thereto for the product. The special conditions are issued 

in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft 

engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that 

established in the regulations. 

See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Leading Edge’s intended operation of the DJI Phantom 3 UASs, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Randy 

Steven Dixon Seeks Exemption: Randy Steven Dixon seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Randy Steven Dixon Seeks: This exemption will 

permit KYLE P NORTON to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support Randy Steven Dixon’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, Randy Steven Dixon’s request for exemption may be granted pursuant to the authority of FMRA 

Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification. As discussed in detail above, Randy Steven Dixon will operate the DJI 

Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, Randy Steven Dixon seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 

DJI Phantom 3 UASs commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization 

and Reform Act of 2012, while also advancing the interests of the public, by allowing Randy Steven 

Dixon to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the 

NAS. THEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, Randy Steven Dixon respectfully requests that the Administrator grant 

this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Randy 

Steven Dixon to operate the DJI Phantom 3 UASs commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: June 6, 2015 Respectfully submitted, Randy Steven Dixon 731 Oak Knoll Circle Auburn, AL 36830

334.444.6238
Appendices: A – DJI Phantom 3 Specifications Data Sheet

Appendices: B – DJI Phantom 3 User Manual

Appendices: C – Monthly Maintenance Log 

APPENDIX – A DJI Phantom 3 TECHNICAL SPECIFICATIONS

DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and location 

information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1 

2.2.1 Aircraft 2.2.1

1 Model – Phantom 3 

2.2.1.2 Weight (Battery Included) – 1280 grams

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: +/- 10cm; Horizontal: +/-1m 

2.2.1.4 Max Angular Velocity –Yaw: 2000/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 3m/s 

2.2.1.8 Max Speed – 16m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 6000m 

2.2.1.10 Max Flight Time – Approximately 23 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

2.2.3.1 Name – Sony EXMOR 

2.2.3.2 Model – 12.4M Pixel 

2.2.3.3 Total Pixels – 12.4M 
2.2.3.4 Effective Pixels – 12.76M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 

1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

2.2.4 Transmitter 2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S